Proposed Dishwasher Efficiency Standards

The Department of Energy (DOE) recently released a proposed rule updating the energy efficiency standards for residential dishwashers. The proposal establishes divergent standards for “standard” and “compact” machines. Interestingly, this rulemaking comes only two years since a 2012 direct final rule regulating dishwashers. The unofficial, pre-publication version of the current proposal is 178 pages.

How the New Congress Can Address Regulation

As the election results fade into distant memories, it’s now time for Congress to switch gears and focus on the policy ramifications of the new political reality. With strong majorities in the U.S. House and Senate, there is little doubt Republicans will heighten their focus on executive overreach and regulatory reform. Below are a few achievable policy prescriptions for regulatory reform in the next Congress.

Comments on EPA’s Carbon Pollution Emission Guidelines for Existing Stationary Sources

We have numerous concerns about the Clean Power Plan, including legal questions over the use of 111(d) in this circumstance, regulatory overreach implied in outside-the-fenceline compliance contributions, timing in relation to other EPA rules, clarity about rate-based or mass-based compliance, and the complications of assembling new regional compliance partnerships. For the purpose of this comment, however, we would like to specifically highlight concerns with four aspects of EPA’s proposed rule, assuming rate-based compliance: 1) costs and employment implications, 2) baseline considerations, 3) feasibility of building blocks, and 4) implementation concerns.

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